The article, written by Gabor Rona, International Legal Director of Human Rights First attempts to disprove the view of those who believe "this is what happens when you put suspected terrorists on trial rather than simply detain them without charge or trial." To that end, Rona notes that although Ghailani may be the first Guantanamo detainee to be tried, approximately 400 cases have been handled by Article III courts since September 11. Moreover, "intelligence, law enforcement and even military personnel are becoming increasingly cognizant of the need to gather admissible evidence to support criminal charges and trials." The result, according to Rona, is that "we should have very few, if any, cases in which persons must be detained but cannot be tried," where intelligence is lawfully obtained.